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UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
-----------------------------------------x
:
UNITED STATES OF AMERICA
:
- v. -
:
USAMA BIN LADEN, INDICTMENT
a/k/a "Usamah Bin-Muhammad :
Bin-Ladin," 98 Cr.
a/k/a "Shaykh Usamah Bin-Ladin," :
a/k/a "Mujahid Shaykh,"
a/k/a "Abu Abdullah" :
a/k/a "Qa Qa,"
:
Defendant.
-----------------------------------------x
COUNT ONEConspiracy to Attack Defense Utilities of the United States
The Grand Jury charges:
Background: Al Qaeda
1. At all relevant times from in or about 1989 until
the date of the filing of this Indictment, an international
terrorist group existed which was dedicated to opposing non-Islamic
governments with force and violence. This organization grew out of
the "mekhtab al khidemat" (the "Services Office") organization
which had maintained (and continues to maintain) offices in various
parts of the world, including Afghanistan, Pakistan (particularly
in Peshawar) and the United States, particularly at the Alkifah
Refugee Center in Brooklyn. From in or about 1989 until the
present, the group called itself "Al Qaeda" ("the Base"). From
1989 until in or about 1991, the group was headquartered in
Afghanistan and Peshawar, Pakistan. In or about 1992, the
leadership of Al Qaeda, including its "emir" (or prince) USAMA BIN
LADEN, the defendant, and its military command relocated to the
[1]
Sudan. From in or about 1991 until the present, the group also
called itself the "Islamic Army." The international terrorist
group (hereafter referred to as "Al Qaeda") was headquartered in
the Sudan from approximately 1992 until approximately 1996 but
still maintained offices in various parts of the world. In 1996,
USAMA BIN LADEN and Al Qaeda relocated to Afghanistan. At all
relevant times, Al Qaeda was led by its "emir," USAMA BIN LADEN.
Members of A1 Qaeda pledged an oath of allegiance to USAMA BIN
LADEN and Al Oaeda.
2. Al Qaeda opposed the United States for several
reasons. First, the United States was regarded as "infidel"
because it was not governed in a manner consistent with the
group's extremist interpretation of Islam. Second, the United
States was viewed as providing essential support for other
"infidel" governments and institutions, particularly the
governments of Saudi Arabia and Egypt, the nation of Israel and
the United Nations, which were regarded as enemies of the group.
Third, Al Qaeda opposed the involvement of the United States
armed forces in the Gulf War in 1991 and in Operation Restore
Hope in Somalia in 1992 and 1993. In particular, Al Qaeda
opposed the continued presence of American military forces in
Saudi Arabia (and elsewhere on the Saudi Arabian peninsula)
following the Gulf War. Fourth, Al Qaeda opposed the United
States Government because of the arrest, conviction and
imprisonment of persons belonging to Al Qaeda or its affiliated
terrorist groups, including Sheik Omar Abdel Rahman.
3. Al Qaeda has functioned both on its own and through
some of the terrorist organizations that have operated under its
2
umbrella, including: the Islamic Group (also known as "al Gamaa
Islamia" or simply "Gamaa't"), led by co-conspirator Sheik Omar
Abdel Rahman; the al Jihad group based in Egypt; the "Talah e
Fatah" ("Vanguards of Conquest") faction of al Jihad, which was
also based in Egypt, which faction was led by co-conspirator Ayman
al Zawahiri ("al Jihad"); Palestinian Islamic Jihad; and a number
of jihad groups in other countries, including Egypt, the Sudan,
Saudi Arabia, Yemen, Somalia, Eritrea, Kenya, Pakistan, Bosnia,
Croatia, Algeria, Tunisia, Lebanon, the Philippines, Tajikistan,
Chechnya, Bangladesh, Kashmir and Azerbaijan. In February 1998, A1
Qaeda joined forces with Gamaa't, A1 Jihad, the Jihad Movement in
Bangladesh and the "Jamaat ul Ulema e Pakistan" to issue a fatwah
(an Islamic religious ruling) declaring war against American
civilians worldwide under the banner of the "International Islamic
Front for Jihad on the Jews and Crusaders."
4. Al Qaeda also forged alliances with the National
Islamic Front in the Sudan and with the government of Iran
and its associated terrorist group Hezballah for the purpose of
working together against their perceived common enemies in the
West, particularly the United States. In addition, al Qaeda
reached an understanding with the government of Iraq that al Qaeda
would not work against that government and that on particular
projects, specifically including weapons development, al Qaeda
would work cooperatively with the Government of Iraq.
5. Al Qaeda had a command and control structure which
included a majlisalshura (or consultation council) which
discussed and approved major undertakings, including terrorist
3
operations.
6. Al Qaeda also conducted internal investigations of
its members and their associates in an effort to detect informants
and killed those suspected of collaborating with enemies of Al
Qaeda.
7. From at least 1991 until the date of the filing of
this Indictment, in the Sudan, Afghanistan and elsewhere out of the
jurisdiction of any particular state or district, USAMA BIN LADEN,
a/k/a "Usamah Bin-Muhammad Bin-Laden," a/k/a "Shaykh Usamah Bin-
Laden," a/k/a "Mujahid Shaykh," a/k/a "Abu Abdallah," a/k/a "Qa
Qa," the defendant, and a co-conspirator not named as a defendant
herein (hereafter "Co-conspirator") who was first brought to and
arrested in the Southern District of New York, and others known and
unknown to the grand jury, unlawfully, willfully and knowingly
combined, conspired, confederated and agreed together and with each
other to injure and destroy, and attempt to injure and destroy,
national-defense material, national-defense premises and national-
defense utilities of the United States with the intent to injure,
interfere with and obstruct the national defense of the United
States.
Overt Acts
8. In furtherance of the said conspiracy, and to effect
the illegal object thereof, the following overt acts, among others,
were committed:
a. At various times from at least as early as 1991
until at least in or about February 1998, USAMA BIN LADEN, the
defendant, met with Co-conspirator and other members of Al Qaeda in
4
the Sudan, Afghanistan and elsewhere;
b. At various times from at least as early as 1991,
USAMA BIN LADEN, and others known and unknown, made efforts to
obtain weapons, including firearms and explosives, for Al Qaeda and
its affiliated terrorist groups;
c. At various times from at least as early as 1991,
USAMA BIN LADEN, and others known and unknown, provided training
camps and guesthouses in various areas, including Afghanistan and
the Sudan, for the use of Al Qaeda and its affiliated terrorist
groups;
d. At various times from at least as early as
1991, USAMA BIN LADEN, and others known and unknown, made efforts
to produce counterfeit passports purporting to be issued by various
countries and also obtained official passports from the Government
of the Sudan for use by Al Qaeda and its affiliated groups;
e. At various times from at least as early as
1991, USAMA BIN LADEN, and others known and unknown, made efforts
to recruit United States citizens to Al Qaeda in order to utilize
the American citizens for travel throughout the Western world to
deliver messages and engage in financial transactions for the
benefit of Al Qaeda and its affiliated groups;
f. At various times from at least as early as
1991, USAMA BIN LADEN, and others known and unknown, made efforts
to utilize non-Government organizations which purported to be
engaged in humanitarian work as conduits for transmitting funds for
the benefit of Al Qaeda and its affiliated groups;
g. At various times from at least as early as
5
1991, Co-conspirator and others known and unknown to the grand jury
engaged in financial and business transactions on behalf of
defendant USAMA BIN LADEN and Al Qaeda, including, but not limited
to: purchasing land for training camps; purchasing warehouses for
storage of items, including explosives; transferring funds between
bank accounts opened in various names; obtaining various
communications equipment, including satellite telephones; and
transporting currency and weapons to members of A1 Qaeda and its
associated terrorist organizations in various countries throughout
the world;
h. At various times from in or about 1992 until
the date of the filing of this Indictment, USAMA BIN LADEN and
other ranking members of Al Qaeda stated privately to other members
of Al Qaeda that Al Qaeda should put aside its differences with
Shiite Muslim terrorist organizations, including the Government of
Iran and its affiliated terrorist group Hezballah, to cooperate
against the perceived common enemy, the United States and its
allies;
i. At various times from in or about 1992 until
the date of the filing of this Indictment, USAMA BIN LADEN and
other ranking members of Al Qaeda stated privately to other members
of Al Qaeda that the United States forces stationed on the Saudi
Arabian peninsula, including both Saudi Arabia and Yemen, should be
attacked;
j. At various times from in or about 1992 until
the date of the filing of this Indictment, USAMA BIN LADEN and
other ranking members of Al Qaeda stated privately to other members
6
of Al Qaeda that the United States forces stationed in the Horn of
Africa, including Somalia, should be attacked;
k. Beginning in or about early spring 1993, Al
Qaeda members began to provide training and assistance to Somali
tribes opposed to the United Nations' intervention in Somalia;
1. On October 3 and 4, 1993, members of A1 Qaeda
participated with Somali tribesmen in an attack on United States
military personnel serving in Somalia as part of Operation Restore
Hope, which attack killed a total of 18 United States soldiers and
wounded 73 others in Mogadishu;
m. On two occasions in the period from in or about
1992 until in or about 1995, Co-conspirator helped transport
weapons and explosives from Khartoum to Port Sudan for
transshipment to the Saudi Arabian peninsula;
n. At various times from at least as early as
1993, USAMA BIN LADEN and others known and unknown, made efforts to
obtain the components of nuclear weapons;
o. At various times from at least as early as
1993, USAMA BIN LADEN and others known and unknown, made efforts to
produce chemical weapons;
p. On or about August 23, 1996, USAMA BIN LADEN
signed and issued a Declaration of Jihad entitled "Message from
Usamah Bin-Muhammad Bin-Laden to His Muslim Brothers in the Whole
World and Especially in the Arabian Peninsula: Declaration of Jihad
Against the Americans Occupying the Land of the Two Holy Mosques;
Expel the Heretics from the Arabian Peninsula" (hereafter the
"Declaration of Jihad") from the Hindu Kush mountains in
7
Afghanistan. The Declaration of Jihad included statements that
efforts should be pooled to kill Americans and encouraged other
persons to join the jihad against the American "enemy";
q. In or about late August 1996, USAMA BIN LADEN
read aloud the Declaration of Jihad and made an audiotape recording
of such reading for worldwide distribution; and
r. In February 1998, USAMA BIN LADEN issued a joint
declaration in the name of Gamaa't, Al Jihad, the Jihad Movement in
Bangladesh and the "Jamaat ul Ulema e Pakistan" under the banner of
the "International Islamic Front for Jihad on the Jews and
Crusaders," which stated that Muslims should kill Americans --
including civilians -- anywhere in the world where they can be
found.
(Title 18, United States Code, Section 2155(b).)
[Blank][Signature]
_________________________ ___________________________
FOREPERSON MARY JO WHITE
United States Attorney
8
[End indictment]